At the 7th International Tax Law Congress, organized by the Administrative Tax Court on Transfer Pricing, the perspectives thereon in Latin America were discussed, which highlighted the increase in the number of Transfer Pricing audits.
Reforms to Tax Regulations
As a result of the actions of the Inclusive Framework of the OECD's Base Erosion and Profit Shifting Project (BEPS), implemented by several countries in the region, through regulatory reforms, the standardization of the supporting documentation of multinational groups has been accomplished, as well as the subjection of the Transfer Pricing regime of taxpayers operating under a preferential tax regime. In addition, the tax administrations have been empowered to request supporting documentation with the requested specifications.
Transfer Pricing Guidelines 2022
Likewise, countries are updating their regulations based on the recommendations of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022.
Increase in Transfer Pricing Audits
The increase in Transfer Pricing audits is expected in structures involving related party transactions without economic substance, expense reimbursements, intra-group services, financial transactions, intangibles, and business reorganizations.
Source: Martes Financiero
